‘STATE OF KANSAS STANTON A. HAZLETT 701 Jackson St. Disciplinary Administrator Floor FRANK D. DIEHL Topeka, Kansas 66603-3729 ALEXANDER WALCZAK Telephone: (785) 296-2486 JANITH A. DAVIS. Fax: (785) 296-6049 Deputy Disciplinary Administrators GAYLE B. LARKIN Admissions Attorney OFFICE OF ‘THE DISCIPLINARY ADMINISTRATOR COMPLAINT FORM GENERAL INSTRUCTIONS: Complete the following form in as much detail as possible, Provide the attomeys full name. If you wish to complain about more than one attorney, complete a separate complaint form for each attomey. If any of the questions do not apply to your case, write N/A in the spaces that are not applicable. FEE DISPUTES: Please be advised that we do not settle fee disputes. If you are disputing the fee paid to your attomey, please contact one of the following Fee Dispute Committees: Johnson County Bar Fee Dispute Committee (913) 780-5460; Sedgwick County Bar Fee Dispute Committee (316) 263-2251; Kansas Bar Association Fee Dispute Committee (785) 234-5696. PROCEDURE: After the materials are received by the Office of the Disciplinary ‘Administrator, an attomey will be assigned to review the documents and supervise the investigation of the complaint. You will be kept informed when action occurs regarding your complaint, Your Name: Claudine Dombrowski Your Address: P.O. Box 4974 City, State, Zip: Topeka, KS 66604 HomePhoneNo: CellPhone No: (785) 845-3617, Work Phone No.: Fax Phone No.: (888) 330-2059 E-Mail Address: _AngelFi sas.net Attomey's Name: M.JillDykes ‘Attorney's Address: _1243S.W. Topeka Blvd, SuiteB City, State, Zip: Topeka KS66612_ Attomey’s Phone No.: (785) 266-8664Did you hire the attorney? Yes No. Ifyes, when did you hire the attomey? Court appointed as GAL, June 24th, 2004-Case No. 96-D-217 How much did you pay the attorney for attomey fees? Please attach a copy of any receipts, cancelled checks, contracts, fee agreements, and engagement letters. What did you hire the attomey to do? Hf no, what is your connection with the attorney? Please explain briefly. [this is my factual statement] Graft, payola, churning, RICO, malpractice, incompetence, dereliction, anti-trust violation, fraud, misfeasance, malfeasance, bribery, price-fixing, unfair trade practices, maltreatment, negligence, abuse, therapeutic jurisprudence. Misrepresentations, deceit, sabotage of Court Orders, falsification of records, misleading the courts; in ail attempts to re establishes parenting time between @ now 13 year old daughter and her mother. Since her appointment there has existed ‘conflict of interest.’ The following years ‘well note’ her bias, prejudice, and alignment with my daughters abuser, to keep mother and child separated, as she promised to do in a recorded conversation with her October 2005 indicates. Intentionally on her own and with assistance destroyed and maintains to this day a ‘complete’ separation other than the most restrictive and oppressive of conditions of my daughter and I. Intentional and malicious- “parental alienation”- is an understatement. With ‘NO “finding of any fact’ — hearsay,{hers and her hand picked MHP’s and other FOC’s] by and through her ‘godly’ powers as a GAL. She has and continues to interfere with parent/child access. There exists- NO ‘finding of fact’ that mother is nor has EVER been alleged to bea threat to her child, not ever! Four years... gone. A child's childhood stolen, exploited, by politicking,-bed swapping, bottom feeders for increased litigation and increased financial personal gain.Is your complaint about a law suit or a criminal case? Yes L%_] No tyes, what is the name of the court? For example, the Kansas Supreme Court, the District Court of Shawnee County, Kansas, the Municipal Court of Topeka, Kansas. District Court of Shawnee County, Kansas What is the title of the case? For example, Jane Smith v. John Doe or State v. ‘Smith, Richardson v. Dombrowski Whats the case number? 96-D-217 Approximately when was the case filed? March 1996 lfyou are not a party to the law suit or the defendant in the criminal case, what is your connection with if? Please explain briefly. {factual statement cont.] As a DIRECT result of the actions of M. Jill Dykes; this case has received National attention and currently as ‘lead plaintif?’ in a suit to the ‘Inter-American Commission Human Rights'- [supported by leading National and State organizations}, filed May 11, 2007. See complete petition with exhibits here: ‘www StopFamilyViolence.org Kansas is hard copy signor to the complaint, press release here: Ittp://www.kesdv.org/psmothers.html M. Jill Dykes is the absolute epitome of incompetent, evil- profiteering at the cost of the very children she is supposed to protect and continues to do- is beyond criminal and appalling, without any ‘conscious’ as to the ‘irreversible’ damage and extent of the trauma she was and still is causing, my child and J. ‘www StopFamily Violence.org Claudine Dombrowski P.O. Box 4974, Topeka, KS 66604 SaH, ACP end.Have you or has a member of your family complained about an attomey in the past? Yes (] NoC tyes, what is the name of the attomey who was the subject of the previous complaint? Approximately when was the previous complaint filed? ‘What was the disposition of the previous complaint filed? FACTUAL STATEMENT: On a separate piece of paper, please prepare a detailed factual statement of your complaint. State the facts as you understand them. Do not include opinions or arguments. Include information about the type of case it was, i.e. divorce, criminal, etc. and when it started. If you employed the attomey also include how you chose the attomey, when you first met with the attomiey, what the fee agreement was, whether the agreement was written or oral, what has happened so far in the case, and the last contact you had with the attomey. ‘Sign and date your statement. Further information may be requested later. Attach copies of pertinent documents. PLEASE BE ADVISED THAT WE CANNOT RETURN DOCUMENTS SUBMITTED TO THIS OFFICE. YOU SHOULD RETAIN A COPY OF ALL MATERIALS YOU SUBMIT. Please send the completed Complaint Form, your detailed statement of complaint, along with any pertinent documents to: Office of the Disciplinary Administrator, 701 Southwest Jackson, First Floor, Topeka, Kansas 66603. % SS ‘SignatureFeb.i2. 2008 11:56AM Lav Offices Ko-8683P. 2/8 LEONARD M, ROBINSON, #08313 2921 Sw Wanamaker Dr., Suite 100 PO Box 67414 , KS 785-228-5680 (telephone) 785-228-5685 (facsimile) for IN THE DISTRICT COURT OF SHAWNEE COUNTY, KANSAS 7 ‘ DIVISION TWELVE. In the Matter of the Marriage oft) i) HAL RICHARDSON ) ‘Case No. 96 D 217 and ) Cuaupive Dovrowse } ) COMES NOW Claudine Dombrowald and makes written objection to the recommendation’ of Domestic Case Manager of February 2004 of follows: te Ciaudine Dombrowski hus not threatened Hal Richardson or caused anyone olse- to threaten him, ‘In support of her position, attached hereto is a February 2004 letter from Ratph 2 (Claudine Dombrowski returned the daughter based upon what she interpreted the parenting plan in conjunction with the Shawnee County Guidelines, : 3 ‘Claudine Dombrowaki at the time of the recommendation of the Domestic Case ‘Manager of Pebruary 2004 had not in fact paid the $112.50 and was unable to in thet her disnbiity payments are being garnished. when, in fect, she owet nothing for support to Hal Richardson, At the time of the filing of this document, the $112.50 probably hes been paid from rooney loaned to Claudine Dombrowski. WHEREFORE, having objected to the Domestic Case Manager's Recommendations of February 2004, Claudine Dombrowski respectfully requests that the Court set the matter for hearing and have an evidentiary hearing dealing with the issues and that the Court not limit her Dareating time with the minor child to supervised visitation in that i is too many steps backward ‘and would be contrary to the best lnerest of the minor child and interfere with the rights of the mother. a te Richardson/Dombrowski Case No, 96D 217 Filed by Pex Page 1Feb-12. 2004 11:56AM Lav Offices No-B609 Po 5 ogo ‘Respectfully submitted, LEONARD M. ROBINSON, #08313 2921 SW Wanamaker Dr., Suite 100 PO Box 67414 ‘Topeka, ‘SERMRICATE OF SERVICE hereby cectify that on the 12° day of February, 2004, a true and correct copy of the above and fropng Wen Oberon we aed ae Gel ae first-class, postage ‘Prepaid addressed to: Clerk of the District Court Chamber Copy: Honoiable David B, Bruns Filed via Fax Shawnee County Courthouse 200 SE 7* st, Donald R. Hoffnan Topeka, KS 66603 112 SE st, ‘Topeka, KS 66603, Lloyd C. Swartz Domestic Case ‘800 SW Jackson St., Suite 900 ‘Topeka, KS 66612-1259 Claudine Dombrowski vin fax et Leonard Mi. Robinson Richardson/Dombrowki Case No, 96D 217 Elied by Eas Pag 2Room 235, Richard Bolling Federal Building 601 E 12 st. Kansas City, Missouri 64106 To Whom It May Concern: My name is Ralph Raposa. I ama Federal Employee of the Department of Health and Human Services. My offices are located at CMS, Room 225, Richard Bolling Federal Office Building, 601 B. 12 St. Kansas City Mo. I also serve on my agency's Domestic Violence workgroup, and have been involved with battered women and abused children for 25 years. on the weekends of January 17,2004 and January 30,2004, Claudine and Rikki Dombrowski were my guests at my home. From the time they arrived on Friday afternoon January 17, 2004, and until they left on Tuesday morning, January 20, 2004, and again, from Friday afternoon January 30 to Tuesday, February 3, 2004, T spent virtually all of my time with both Rikki and her mother, as well as did my own ten year old son. There was never any discussion that I heard between anyone to suggest that arrangenents were being made to harm Riki's father by BACA or by anyone else. In fact, I was the one who suggested Rikki and her Mom meet with BACA since Rikki was interested in the global issue of child abuse, and her mother was a motorcycle enthusiast. I am not a member of BACA, but was aware of their existence through my other Domestic Violence interests. I£ I may be so bold as to opine on this motion, based on some 25 years ‘experience working with battered women and abused children, and while I am not a clinician, my experience and the evidence convinces me that we are dealing in the instant case with a classic case of utilization of the legal system as a method of intimidation by the father. As such, and not withstanding that perspective, I see nothing presented in this motion that carries any probative value of a connection with the mother with any of the allegations, other than Claudine admits she owes the monies cited in current Case managers Recommendations of $112.50, and is submitting a check to resolve that matter. Otherwise, none of the case manager's recommendations, in my view, is based on objective evidence of such probative value that the drastic measures being proposed have any merit. In fact, it appears most of the evidence consists of interpretations and baseless allegations by the father rather than hard, material evidence. Mr. Richardson himself could have delivered his own threat letter as easily as anyone else. I trust the envelope and post mark have been analyzed for place of origin. With internet technology and free speech being what it is, there is a plethora of possible sources of this letter. BACA is a completely independent and fully sanctioned non-profit organization that educates the general public on child abuse matters, as well as making interventions on behalf of the custodial parent where such interventions are both legal and warranted. They work with local community organizations and local social service agencies. Nothing suggests in my review of the alleged “threat letter” that the so-called threat came from BACA, or anyone else affiliated with Ms. Dombrowski. To sever her ties with her daughter based on such shoddyevidence serves no useful purpose, other than to foster the personal ongoing agenda of control and intimidation by Mr. Richardson against Ms. Dombrowski, in my view. I recognize Mr. Richardson is the custodial parent in this case, but I think any review of the evidence and history of this case speaks for itself. I am happy to be deposed or offer any testimony the courts find material. Feel free to call my office at (816) 426-6546. Sincerely yours, Ralph Raposa Ce: Hon. David E. Bruns Clerk of the District Court Shawn B.A.C.A National Leonard M. Robinson Dr. W. Albott Dr. Rodeheffer Lloyd C. Swartz County, KansasMER. 2.2085 10:55am SAFE VISIT PRogRaN No.a77 P22 Kuehne Family YMCA — YMCA Safe Visit : : Satellite Office snaanwTavion Toes, Kanses 65608 (189) 1446877 Fan (185) 234-5466 ‘email safevisit@ kansas. c6¢ ‘The Honorable Bvelya Wilson ‘Shawnes Co, District Cout: Div. 5 200. 7* Topol, KS. 6660 Case No. 96D217: Clandine Dombrowski & Hal Richardson, Jr. ‘March 1, 2005 Dear Judge Wilson, "This is on update on the sbove-mentioaed case, which vomes before the Court 3-3-05. In early 2004, it was recommended that Claudine have supervised visitation with her daughter, Rikki, Hal contacted the program on 2-34} to re-establish services. Staff reviewed the Program guidelines with him on 2-4.04. C)andine did not contuc the bfogram unuli 9-1-04. ‘Shie wet with Staff on 2 9 04 to review guidatinne Te to the Program's schedule visits were unable to begin until 9-29-04, Visits were scheduled for avery Wednesday from 6:30pin-7:30pm. The visits moved to every Sunday from 4:00pm- 5:00pm on 1-30-05 at Hal's eoquest and to bettor able to accommodate anather family im the program, Paymont is assexsei! Ww Claudine, She has a.zero balance at this time, “rhaea have baen 73 vieire echevinted snl 21 have occusred. The visit om 12-1-04 was cancelled 80 Claudine could attend Rikki's Gitl Scout dinucr that same evening, and the visit om 1-5-05 was cancelled eine to the Program being closed because of bad weather. CCiaudine bas beought snacks and activides for her und Rikki to share during the visits. They have msde craft items together and have talked about school, people they know, said aztivities each are involved in, Rath display physical affectiog, hugs and kisscs with the other, Claudine often tells staff this is her best day nf the week as she yeis to see Rikki. Nothing inappropriate has been said or done chiring the visits. Bot partes have ‘srived and departed at their appointed times snd have followed the Program guidelines. Rikki transitions egsily from the drop off, to the visit, and with the pick up. After the visit on 11 17-04, Rikki talked with staff shout how she was feeling ahout Claudine coming to cat lunch with her at school. She expressed some discomfort with Pt ia ali er uishnanas ae ui to goby when abe was young, Seid tba kids would tease her, Staff cnoouraged her to talk with her mother about the things that bother her. Rikki said she has but her mother docen’t listen, At the visits, Clandine bas refesred to Rikki as “her princess” and sings songs as they do activities but Rikid ‘Joes nut voice any opposition to Claudine about her comments or behavicrs, i This progr foided i Dart by grant provided bythe Uinted Wry. Shawnee County, City uh Seruces ad, the Soe Chad Exch and ican Cond Prepon onthe Perel ae cat on Von Progr or dvi by Ratan ncmay Conn an Tu Govan of Kant(eR, 2.2085 18:56AM — SAFE VISIT PROGRAM NOM? PBB Staff has been in contact with the GAL, Iill Dykes, as well 28 the Case Manager, Toya Swarm, regarding points of ubsecvation and on « need to know basis stoes of parant/ohild contest and commmnicmion, Please notify Safe Visit if there arc any changes that need to be made regarding the visitation plan, rE. Connie Sanches, Safe Visit Administra. co: Claudine Dombrowski, Pro Se ‘Don Hoffman, Att. for Hal ‘Ail Dykes, GAL Lloyd Swartz, Case Manager Safe Visit staf doet not provide evaluations of the femilier wko ute the program's services or make parental80/82/2005 15:49 17052928000 GOLLAZD LAW OFT TOL race The Law Office of M. Jill Dykes 1243 §.W. Topcka Blvd., Suite B telephone: 785-266-8664 Topeka, Kansas 66612 fax: 785-232-0600 e-mail: faith_full_ @hotmail.com eos ene er Mareh 2, 2005 ‘The Honorable Evelyn Wilson Shawnce County Courthouse 200SE. 7 Street Division 5 Tupeka, Kansas 66603 Re: Richardson v. Dombrowski, Case 86-D-217 Dear Judge Wilson, As you may recall, Tam Guardian ad Litem for Rikki Dombroski, the minor child of Hal Richardovu wal Clawlin Dumlivwokl. The aver 1¥ CUTONLY set on tomorow’s states docket for reviow. Ihave received and reviewea Jenny Shaw's letter to the Court dated March 1, 2005, ‘and wanted (o share with the Court the following, On February 28, 2005, I spoke with Rikki's therapist, Dr. Rodeheffer, sbout Rikic and about his recommendations regarding the use of the Safe Visit Program. Dr. Rodehoffor indicated to me that be had recently mot with Rildei and that thoy disvunsedl hes visits with ber mother. According to Dr. Rodehetter, Rikki continues to express concerns about visitation with ‘her mother. Specitic conoems involve Claudine continuing to make unirue vommemts about het father to others who then in tum relay theso comments to Rikki, This is frustrating to Rid and canses her unnecessary stress, Dr. Rodeheffer feels that the Suft: Visit Program provides » safe and stable environment in which Rikki can Lave ountat with cr mother, He recommends that the Court continue to utilize this seavive so that Rikki can continue to benefit from the structure provided and in time ‘sow inure secure in her relationship with her mother I concur with Dr. Rodeheffer's rconmmencdation snd would urge the Court to continue visitation with the safe visit program until my client and her therapist feel comfortable82/02/2005 15:49 17052920600 COLLAZD LAW OCTIOD nace discontinuing the Rildci has lid (o endure so much this and she: ‘chauue mo Plax and enjoy JUST Deng Ae for nchange et oe oe In order for this eecur, 1 would further ask the Court to admonish Ma, Dombrowski to keep her feelings about Mr. Richardson to herself. She may aot be inlentionally saying these thmgs with the intent that they be relayed to Riki, however this is hat ls occuring. Dr. Rodahaffar Firmly believes that itis this very behavior which is alienating BRikhi (iven hex mothor nd causing hr to want to pull back fruus le Ba ‘Thank you for your attention to this mutter. ‘Sincerely, Wl pine Dog Kes M. Jill Dykes Attorney at Law ec: Don Hoffman ‘Lloyd Swartz Claudine Dombrowski Dr. Rodeheffer a9KANSAS DISTRICT COURT Shawnee County Courthouse Officer Chanbers of ‘Division No. Twelve PeLACTA DAVID E. BRUNS Topeka, Kansas 6603-3922 Admiisrave DISTRICT JUDGE (785)353-8200 Ft, 4405 DOROTHY SHEL, CSR, RFR FCRR. June 24, 2004 Claudine Dombrowski PO Box 15212 Kansas City, MO 64106 : Donald R. Hoftinan Attomey At Law 112 SE Tth St. Topeka, KS 66603 RE: Richardson v. Dombrowski Case No. 96 D217 LETTER DECISION Dear Ms. Dombrowski and Mr. Hoffinan: Court Services has completed the investigation ordered in this case pursuant 10 KS.A. 60-1615. During her investigation, Amanda Smith reviewed numerous documents, obtained records from several sources and conducted multiple interviews, cifically, Ms. Smith spoke to the child’s third grade teacher, the Principal at ‘Tecumseh North Elementary School, representatives of the Girl Scouts, including Vieki ‘Ash, and Dr, David Rodeheffer. At the Court’s direction, Ms, Smith also conducted an unscheduled interview with ‘the minor child in order to receive her input regarding the various events which led to the ‘Case Manager's recommendation for supervised parenting time. Pursuant to K.S.A. 60- 1615(c), Ms. Smith has prepared a written report which has been presented to the Court It should be noted that the report does not contain any recommendations but simply a summary of the investigation,Richardson v. Dombrowski Case No, 96 D217 Under the circumstances presented in this ease, the Court does not believe that release of Ms, Smith’s report would be in the best interest of the minor child. If the Court ‘were to release the report to one party, it would need to disclose the report tothe other party in the interests of firmness. However, as more fully discussed below, the Cour is ‘appointing a Guardian Ad Litem to serve in tis case and she willbe permitted to review ‘the repors in her positon as an advocate forthe best interests ofthe child ‘Turning to Dr. William Albot’s request to be released from further court-ordered “duties in this ease, the Court finds that his request should be and itis hereby granted. The ‘Court thanks him for is service. Likewise, Dr. David Rodehefferis hereby released from further court-ordered duties inthis ease. The Court also appreciates his service. ‘Moreover, Amanda Smith is hereby released from further investigatory duties in this ease ‘and the Court thanks her for her service. 1 should be noted that Division 12 has been advised that it will no longer be handling aay domestic cases once a new judge is appointed to replace the Honorable James M. Macnish, fa the near futur, this case willbe transferred to one of the four (4) {judges in the newly established Family Law Department. In fac, this Division has ‘already been assigned all of Judge Macnish’s civil cases as well ns numerous civil eases, from other Divisions. Thus, tho amount of time which this Court will have #9 spend on ‘any particular case will be extremely limited over the next couple of months. Inan attempt to determine what, ifanything, this Court could do to help the minor child, it has reviewed the entire cout fle. Te review reveals that there have been many juges and attomeys involved in this ese prior o this Court being assigned this ease as zesult of Judge Schmidt's recusal in July of 2003. Unfortunately, ithe lengthy history of this case serves a a guide, there will likely be several more judges and atomeys involved ‘efor the child eaches the age of majority. ‘There is one thing, however, which appears tohave been missing inthis voluminous file, Although there has been a great deal of zealous advocacy fo both parents over the years, nobody has served as an advocate on behalf of the Notwithstanding the substantial disputes between the parties, it appears that they bath recognize the nced for someone to serve as an advocate for their daughter. ‘The Court notes thatthe Petitioner's attorney stated in his April 27th letter to the Case Manager that “[iJt seems to me that itis Rikki who is being let down by all of us in positions of responsibility in this case.” Similarly, the Court notes in Dr. Rodeheffer’s record for March 25, 2004, thatthe Respondent told him that “nobody is advocating for ‘my daughter..." Unfortunately, these statements appear to be accurate.Richardson v, Dombrowski Case No. 96 D 217 Although a Case Manager attempts to make decisions which are inthe best interests of a minor child, he or she is not an advocate for the child. Likewise, although a judge must attempt to determine what isin the best interests of a minor child, he or she is not an advocate for the child, Moreover, the primary duty of attomeys representing patents in a divorce action is not to serve as an advocate for the children of ther clients, ‘Thus, the Court believes itis appropriate in this ease to appoint a Guardian Ad Litem whose only duty will be to advocate for the best interests of the minor child, The Court hereby appoints Jill Dykes to serve as Guardian Ad Litem in this case. Ms. Dykes is an experienced attomey and also an experienced Guardian Ad Litem. Fier role in this case shall be as set forth in Kansas Supreme Court Administrative Order No. 100 (2003). (A copy is enclosed and incorporated herein by reference.) The Court hhateby ovdets that Shawnee County advance the Guardian Ad Litem’s initial fee of $225, ‘Any additional fees and expenses by the Guardian Ad Litem will be assessed ata later date, ‘The Guardian Ad Litem, as an advocate for the minor child’s best interest, shall have access to all reports, records or other information concerning this ease. Since ‘Administrative Order No. 100 states that “[cJontinuing investigation and ongoing contact ‘with the child arc mandatory,” the appointment of a Guardian Ad Litem should also bring ‘a degree of continuity to this case which appears to have been lacking. The Court anticipates that once the Guardian Ad Litem has become familiar with this case that she ‘will be advocating for a long-term Parenting Plan which is truly in the best interests of the child. As far as Case Management is concerned, the Court will yield to the judge t0 ‘whom this case is reassigned. That judge should be the one to decide whether he or she believes the continued assistance of a Case Manager would be helpful. ifso, hat judge Should also be the one (o deteruuine wheter the eairent Case Manager should continue in that position or ifa replacement should be named. Regardless, it should be noted that this Court has found Mr. Swartz’s assistance as a Case Manager to be helpful in an extremely difficult case and it thanks him for his service. ‘The Court notes that inthe Petitioner's most recent motion she states that she has fot seen her daughter fora long period of time. Although itis recognized that there were problems related to the parenting time which was to be supervised by Dr. Rodehefer, this Court has never prohibited the Petitioner from seeing her child. In fact, the Petitioner is strongly encouraged to spend time with her daughter.Richardson v. Dombrowski Case No, 96 D217 If there isa problem with the parties utilizing the services ofthe YMCA Saf Visit ‘acilty in Topeka, the Guardian Ad Litem may wish to consider utilizing The Farm in Lawrence for supervised parenting time on a temporary basis and perhaps for monitored ‘exchanges in the future. This appears be a reasonable altemative since the Petitioner lives in Kansas City and the Respondent lives inthe eastem part of Shawnee County. Regardless, the Guardian Ad Litem should approach ths issue, as well as any other Which may be presented inthis ease, from the perspective of what is in the best interests of the child rather than from the perspective of what is best for the parents. “The Court sincerely hopes that unsupervised parenting time can and will be reinstated at some point in the foreseeable future. Rarely i ever, should supervised parenting time to be considered to be a long-term solution in a divorce ease. However, ‘the Court does not find it to be in the best interests of the minor child to lift the requirement of supervision at Us point in time based upon a review of the investigation report and supporting documents submitted by Amanda Smith of Court Serviees. Inthe interim, both parties are directed to fully cooperate with the Guardian Ad Litem in order to develop a parenting plan which is inthe best interests oftheir child “This letter shall serve as an order of the Court. No further Journal Entry is required, Entered by, David E. Bruns District Court Judge Dr, William L. Albott, Jill Dykes, GAL Dr. David Rodehotir ‘Amanda Smith, Court Services Lloyd Swartz, Case Managere2yar/2ee7 1250 7es2320500 oLLazo Lats ore ICE pace 91/08 t 394 - 1786 To: Comm Sanch wo Safe Vist Shank - yee! wo Sin only. - MA. Que Sughs wee we ror aseScio 67 OLERK 43 bfermer COURT Flo JUDICIAL DIST. MILL DYKES, #16096 2 soothe oy aa ; 120 SW Tope Bis, Se. B fam 9 20 AM 8 42 ‘Topeka, Kansas 66612 785.266.8658, IN THE DISTRICT COURT OF SHAWNEE COUNTY, KANSAS DIVISION POUR Inthe Mater of the Mariage of: HALLECK RICHARDSON, Petitioner » Case No: 96-D.217 CLAUDINE DOMBROWSKI, ‘Respondent. ‘MOTION TO ALLOW DOCTOR TO OBSERVE SAFE VISIT (COMES NOW, M. Jill Dykes, Guardian ed Litem forthe minor child inthe above captioned ‘nse, and respectfully requests the Court for an order allowing the minor child's therapist, De. Rodeheter to observe the safe visit bervecn the minor child and her mothor scheduled for ‘September 23%, 2007. In support of sid Motion counsel tes as follow: 1, That the minor ehild as been in therapy for sometime with Dr, Rodeheffe. 2% That the Court has been repeatedly asked by the respondent to alter the current parcoting time plan. 3. That ie minor chile therapist hasbeen asked to provide bis opinion re: paren ‘me in the past end wil wadoutyedly be asked 1 reader his opinion re: these issues syxin inthe Ste, 4, THat it would be in the bas interests ofthe ninr hil for her therapist tobe able to ec 00 oa OFFIosvan/2007 7982220690 observe her interaction with Der mother et the ste visit location so that Dr, Rodehefer will be abe to make informed recommendations tothe Court re future parenting time, ‘The case hms een scheduled fora review hearing on November 8, 2007, «11:00 The respondent as voiced her objection to safe visit stating hat she wil not ‘operate unless there i « Court Onde. ‘Respectfilly submitted, STATES Fes ‘Asiomey at Tae 1243 8.W. Topeka Blvd, Ste. B “Topeka, Kansas 66612£0 ros2228600 COLLARD Lav GrFce Pace 0 raven by CLERK Claudines 4.8. DISTRICT COURT Cop MILL DYKES, #16095 nap auoioucoist. atlaw ‘TOPEKA, 1283 SW. Topeta Biv, ste % Topeka, Kansas 66612 aa sep 20 AA 9 7a 266-68 'NVTHEDISTRICT COURT OF stawNEE COUNTY, Kansas DIVISION FOUR Inthe Maite of the Marige of - HALLECK RICHARDSON, Pathioner Case No: 960-217 CLAUDINE DoMBROWs«x, Responint. TIS SO ORDERED,os/au/2087 1250 7052220600 COLLAZO Lal ur = ‘THE HONORAMIEJOSEPHD. JOIINSON Sudge ofthe District Cour, PREPARED AND APPROVED BY: ‘ Mi Ti Dyes, 16006 ‘Attorney at Law 1243 S.W. Topeka Blvd, ‘Topeka, Kansas 66612 85) 266-8608